State v. Osvaldo Guadalupe Arenas, 161 Idaho 642

During a traffic stop officers learned of an outstanding arrest warrant for Arenas; he was told he was under arrest, asked if he had anything on him, said “No,” handcuffed, and patted down.
An officer felt a "familiar object" in Arenas’ pocket, said, “I thought you had nothing on you, dude,” and Arenas replied it was a “meth pipe.” The officer then removed the pipe.
A subsequent vehicle search uncovered methamphetamine and paraphernalia. A second officer read Miranda warnings and Arenas admitted having methamphetamine in his waistline.
State charged Arenas with felony possession of methamphetamine and misdemeanor paraphernalia; Arenas moved to suppress evidence and statements.
The district court found the initial stop unlawful but held the arrest warrant attenuated the taint; it suppressed the vehicle search but denied suppression of Arenas’ admission that the pocket object was a pipe.
Arenas conditionally pleaded guilty to the felony, reserved the right to appeal the partial denial of the suppression motion, and appealed the admission of his statement about the pipe.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Arenas’ statement that the pocket object was a “meth pipe” must be suppressed as the product of custodial interrogation without Miranda warnings	State: The statement related only to misdemeanor paraphernalia (not the felony pleaded) and is not subject to suppression as moot	Arenas: He was in custody (handcuffed, told he was under arrest) and the officer’s directed comment was reasonably likely to elicit an incriminating response, so Miranda warnings were required	The Court held the issue is not moot and the officer’s comment was a custodial interrogation under Miranda/Innis; the statement must be suppressed

Miranda v. Arizona, 384 U.S. 436 (establishes custodial interrogation/Miranda warnings requirement)
Rhode Island v. Innis, 446 U.S. 291 (defines interrogation to include words or actions police should know are reasonably likely to elicit incriminating responses)
Berkemer v. McCarty, 468 U.S. 420 (custody measured by objective freedom-of-action standard)
Stansbury v. California, 511 U.S. 318 (custody inquiry focuses on objective circumstances)
Arizona v. Gant, 556 U.S. 332 (limits searches incident to arrest of vehicles)
Murphy v. Hunt, 455 U.S. 478 (mootness doctrine and exceptions)
State v. James, 148 Idaho 574 (discussing factors for custody analysis under Idaho law)